April 3, 2012, SC DHEC SIP Amendment

Attachment A ‐ November 3, 2009, Certification for PM

Infrastructure SIPs

SC DHEC SIP Amendment 

April 3, 2012

Attachment A 

Page 1
This page intentionally left blank

SC DHEC SIP Amendment 

April 3, 2012

Attachment A 

Page 2
BOARD: 

Paul C. Aughtry, 111 

Chairman 

Edwin H. Cooper, 111 

Vice Chairman 

BOARD: 

Henry C. Scott 

Steven G. Kisner 

Secretary C. Earl Hunter, Commissioner 

M. David Mitchell, MD 

Glenn A. McCall 

Coleman F. Buckhouse, MD 

Promoting andprotrcting the health of the public and the environment 

November 3,2009 

Richard A. Schutt, Chief, Air Planning Branch 

EPA Region 4 

Atlanta Federal Center 

61 Forsyth Street Southwest 

Atlanta, Georgia 30303-8909 

Re: Clarification to the South Carolina Fine Particulate Matter Air Quality Implementation 

Plan: CAA 110(a)(2)(G) requirements for the 1997 PM2.5 and 2006 PM2.5 NAAQS 

Dear Mr. Schutt: 

The Department of Health and Environmental Control (Department) would like to clarify that it has met 

the basic or infrastructure requirements enumerated in the Clean Air Act (CAA) section 1 10(a)(2)(G). 

On March 14,2008, and September 18,2009, the Department submitted revisions to its State 

Implementation Plan (SIP) to the United States Environmental Protection Agency (EPA) Region 4. 

These revisions to the SIP specifically addressed the Department's obligations under sections 1 10(a)(l) 

and (2) of the CAA, to address basic SIP requirements, including emission inventories, monitoring, and 

modeling to assure attainment and maintenance of the 1997 and 2006 National Ambient Air Quality 

Standards (NAAQS) for fine particles or PM2.5 (particles with an aerodynamic diameter less than or equal 

to a nominal 2.5 mircometers). 

On September 25,2009, the EPA released its Guidance on SIP Elements Required Under Sections 

11 0(a) (I) and (2) for the 2006 24-Hour Fine Particle (PM2.3 National Ambient Air Quality Standards 

WQS). This guidance clarified that "to address the section 110(a)(2)(G) element, states with air 

quality control regions identified as either Priority I, IA or Priority I1 by the 'Prevention of Air Pollution 

Emergency Episodes' rule at 40 CFR 51.150, must develop emergency episode contingency plans." 

Therefore, the requirement for a state to submit an emergency episode plan is based on a priority region's 

classification. 

In its aforementioned guidance, the EPA states that "until the Agency finalized changes to the emergency 

episode regulation to establish for PM25 specific levels for classifying areas as Priority I, IA, or I1 for 

PM2.5, and to establish a significant harm level (SHL) ..." it recommends that state's with a 24-Hour PM2.5 

concentration above 14oPg/m3 (using the most recent three years of data) develop an emergency episode 

plan. 

Per discussions with Region 4 staff at its monthly meeting (on October 2 1,2009), states that do not meet 

the aforementioned proposed threshold would be classified as Priority I11 areas, and therefore, would not 

be required to develop an emergency episode plan for PM2.5. 

The Department is certifying to the EPA that it is indeed classified as a Priority I11 area and that it has 

never exceeded, in any area of the state, the suggested threshold of 140C(g/m3 for either the 24-hour 1997 

PM2 NAAQS or the 2006 PM2, NAAQS. Based on these criteria, South Carolina is not required to 

adopt an emergency episode plan for PM2 5. The Department makes this determination based on the 

SOUTH CAROLINA DEPARTMENT OF HEALTH A N D E N V I R O N M E N T A L CONTROL 

2600 Bull Street Columbia, SC 29201 Phone: (803) 898-3432 www.scdhec.gov 

SC DHEC SIP Amendment 

April 3, 2012

Attachment A 

Page 3
Mr. Schutt 

November 3,2009 

Page 2 

aforementioned guidance and documented conversations with EPA, noting that EPA ha$ yet to complete a 

rulemaking to establish a significant harm level for PM2 5. 

In both its previous SIP revision submittals, the Department further clarified that pursuant to South 

Carolina Statute (S.C. Code Ann. 5 48-1-290 and 5 1-23-130), the Department has the slatutory authority 

to order immediate action to establish emergency regulations to "protect the public health or property." 

Given this clarification to both its previous submittals, the Department is confident that it has met the 

elements necessary under the CAA section 1 10(a)(2)(G). Should you have any further buestions, please 

feel free to contact Maeve S. R. Mason of my staff at (803) 898-2230 or masonmr@,dhe~.sc.aov. 

Robert J( ~rowd~r., Director 

Division of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

ec: Lynorae Benjamin, Chief, Regulatory Development Section, EPA Region 4 

Zuri Farngalo, Environmental Scientist, EPA Region 4 

Joel Huey, PM Coordinator, EPA Region 4 

Steven M. Scofield, Air Planning Branch, EPA Region 4 

Myra C. Reece, Chief, Bureau of Air Quality, SCDHEC 

Renee Shealy, Assistant Bureau Chief, Bureau of Air Quality, SCDHEC 

SC DHEC SIP Amendment 

April 3, 2012

Attachment A 

Page 4